Privacy Notice

Introduction

This privacy notice aims to inform you about how we collect and process any information that we collect from you, or that you provide to us. It covers information that could identify you (“personal information”) and information that could not. In the context of the law and this notice, “process” means collect, store, transfer, use or otherwise act on information. It tells you about your privacy rights and how the law protects you.

We are committed to protecting your privacy and the confidentiality of your personal information. Our privacy notice is not just an exercise in complying with the law, but a continuation of our respect for you and your personal information.

We undertake to preserve the confidentiality of all information you provide to us and hope that you reciprocate.

Our privacy notice complies with the Data Protection Act 2018 (Act) accordingly incorporating the UK General Data Protection Regulation (GDPR).

Your rights

Under the Data Protection Act 2018 and the GDPR, you have several rights which may apply to the services we provide including the right:

• to ask us for copies of your personal information (the right of access).
• to ask us to rectify information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete (the right to rectification).
• under certain circumstances, to require us to delete your personal information (the right to be forgotten).
• under certain circumstances, to require us to restrict processing of your personal information e.g. if you contest the accuracy of the data (the right to restrict processing).
• under certain circumstances, to receive the personal information you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party (the right to data portability).
• under certain circumstances, to object to our continued processing of your personal information e.g. processing carried out for the purpose of our legitimate interests (the right to object).

You can withdraw your consent to future processing at any time, but this right cannot be applied to data already processed.

For further information on each of those rights, including the circumstances in which they apply, please contact us.

Except as set out below, we do not share, or sell, or disclose to a third party, any information collected through our website.

Data we process

We may collect, use, store and transfer different kinds of personal data about you. We have collated these into groups as follows:

Your identity includes information such as first name, last name, title, date of birth, and other identifiers that you may have provided at some time.

Your contact information includes information such as billing address, delivery address, email address, telephone numbers and any other information you have given to us for the purpose of communication or meeting.

Your financial data includes information such as your bank account and payment card details.

Transaction data includes details about payments or communications to and from you and information about products and services you have purchased from us.

Technical data includes your internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.

Marketing data includes your preferences in receiving marketing from us; communication preferences; responses and actions in relation to your use of our services.

We may aggregate anonymous data such as statistical or demographic data for any purpose. Anonymous data is data that does not identify you as an individual. Aggregated data may be derived from your personal data but is not considered personal information in law because it does not reveal your identity.

For example, we may aggregate profile data to assess interest in a product or service.

However, if we combine or connect aggregated data with your personal information so that it can identify you in any way, we treat the combined data as personal information, and it will be used in accordance with this privacy notice.

Special Category personal information

Special Category personal information is data about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data.

It also includes information about criminal convictions and offences.

We may collect special personal information about you if there is a lawful basis on which to do so.

If you do not provide the personal information we need

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform that contract. In that case, we may have to stop providing a service to you. If so, we will notify you of this at the time.

The bases on which we process information about you

The law requires us to determine under which of six defined bases we process different categories of your personal information, and to notify you of the basis for each category.

If a basis on which we process your personal information is no longer relevant, then we shall immediately stop processing your data.

If the basis changes then if required by law, we shall notify you of the change and of any new basis under which we have determined that we can continue to process your information.

Information we process with your consent

Through certain actions when otherwise there is no contractual relationship between us, such as when you browse our website or ask us to provide you more information about our business, including job opportunities and our products and services, you provide your consent to us to process information that may be personal information.

Wherever possible, we aim to obtain your explicit consent to process this information, for example, by asking you to agree to our use of cookies.

We continue to process your information on this basis until you withdraw your consent, or it can be reasonably assumed that your consent no longer exists.

You may withdraw your consent at any time by instructing us dpo@healthhero.com. However, if you do so, you may not be able to use our services further.

Information we process for the purposes of legitimate interests

We may process information on the basis there is a legitimate interest, either to you or to us, of doing so.

Where we process your information on this basis, we do after having considered:

• whether the same objective could be achieved through other means
• whether processing (or not processing) might cause you harm
• whether you would expect us to process your data, and whether you would, in the round, consider it reasonable to do so

For example, we may process your data on this basis for the purposes of:

• record-keeping for the proper and necessary administration of our organisation.
• responding to unsolicited communication from you to which we believe you would expect a response
• protecting and asserting the legal rights of any party
• insuring against or obtaining professional advice that is required to manage business risk
• protecting your interests where we believe we have a duty to do so

Information we process because we have a legal obligation

Sometimes, we must process your information to comply with a statutory obligation.

For example, we may be required to give information to legal authorities if they so request or if they have the proper authorisation such as a search warrant or court order.

This may include your personal information.

Complaints regarding content on our website

If you complain about any of the content on our website, we shall investigate your complaint.

If we feel it is justified or if we believe the law requires us to do so, we shall remove the content while we investigate.

Job application and employment

If you send us information in connection with a job application, we may keep it for up to one year in case we decide to contact you at a later date.

For further details please see our Prospective Employee Privacy Notice.

Video Recording on HealthHero Premises

Video Recording is in place on HealthHero sites in order to:

• Protect staff and contractors
• Protect HealthHero infrastructure and assets  
• Provide a deterrent effect and reduce criminal activity 
• Increase personal safety and reduce the fear of crime

The video system is not used for any other purpose, such as to monitor work of employees or attendance and primarily captures HealthHero entrances and exits. If you are a guest or visiting HealthHero sites, please note that some parts of your visit may be recorded.

HealthHero only collects video footage and does not capture audio. Images can be accessed by the IT services team and all video footage is stored for 30 days before being automatically erased. Under certain circumstances, such as a security investigation, surveillance footage may be downloaded and stored securely while the investigation is ongoing.  

If you have any queries or requests concerning your data, please contact us via the details below

Communicating with us

When you contact us, whether by telephone, through our website or by e-mail, we collect the data you have given to us to reply with the information you need.

We record your request and our reply to increase the efficiency of our organisation.

We keep personally identifiable information associated with your message, such as your name and email address to be able to track our communications with you to provide a high-quality service.

Affiliate and business partner information

This is information given to us by you in your capacity as an affiliate of us or as a business partner.

It allows us to recognise visitors that you have referred to us, and to credit to you commission due for such referrals. It also includes information that allows us to transfer commission to you.

The information is not used for any other purpose.

We undertake to preserve the confidentiality of the information and of the terms of our relationship.

We expect any affiliate or partner to agree to reciprocate this privacy notice.

Use of information we collect through automated systems when you visit our website

Cookies

Our website uses cookies. They are placed by software that operates on our servers, and by software operated by third parties whose services we use.

Cookies are small text files that are placed on your computer’s hard drive by your web browser when you visit any website. They allow information gathered on one web page to be stored until it is needed for use on another, allowing a website to provide you with a personalised experience and the website owner with statistics about how you use the website so that it can be improved.

Some cookies may last for a defined period, such as one day or until you close your browser. Others last indefinitely.

Your web browser should allow you to delete any you choose. It also should allow you to prevent or limit their use.

When you first visit our website, we ask you whether you wish us to use cookies. If you choose not to accept them, we shall not use them for your visit except to record that you have not consented to their use for any other purpose.

If you choose not to use cookies or prevent their use through your browser settings, you will not be able to use all the functionality of our website.

We use cookies in the following ways:

• to track how you use our website
• to record whether you have seen specific messages we display on our website
• to keep you signed in to our website
• to record your answers to surveys and questionnaires on our site while you complete them
• to record the conversation thread during a live chat with our support team

We provide more information about the cookies we use in our cookie policy.

Personal identifiers from your browsing activity

Requests by your web browser to our servers for web pages and other content on our website are recorded.

We record information such as your geographical location, your Internet service provider, and your IP address. We also record information about the software you are using to browse our website, such as the type of computer or device and the screen resolution.

We use this information in aggregate to assess the popularity of the webpages on our website and how we perform in providing content to you.

If combined with other information we know about you from previous visits, the data possibly could be used to identify you personally, even if you are not signed in to our website.

Our use of re-marketing

Re-marketing involves placing a cookie on your computer when you browse our website to be able to serve to you an advert for our products or services when you visit some other website.

We may use a third party to provide us with re-marketing services from time to time. If so, then if you have consented to our use of cookies, you may see advertisements for our products and services on other websites.

Disclosure and sharing of your information

Information we share with and obtain from third parties

From time to time we share your personal information with outsourced third parties to deliver our services and for other purposes set out in this notice.

In addition, we may sometimes receive data that is indirectly made up from your personal information from third parties whose services we use.

No such information is personally identifiable to you.

Data may be processed outside the European Union

Data processed through our website is stored and hosted within the EU.

We may also use outsourced services in countries outside the European Union from time to time in other aspects of our business.

Accordingly, data obtained within the UK or any other country could be processed outside the European Union.

For example, some of the software our website uses may have been developed in the United States of America or in Australia.

We use the following safeguards with respect to data transferred outside the European Union:

• the processor is within the same corporate group as our business or organisation and abides by the standards and safeguards regarding data processing.
• the data protection clauses in our contracts with data processors include Standard Contractual clauses written by or approved by a supervisory authority in the European Union or the United Kingdom, specifically that in the country of the United Kingdom.

Control over your own information

Your duty to inform us of changes

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes by emailing info@healthhero.com

Access to your personal information

Should you wish to exercise any of your rights, you may make that request, including access to information held about you by emailing dpo@healthhero.com or writing to:

The Data Protection OfficerHealthHero Group Limited 10 Upper Berkley StLondonW1H 7PEUnited Kingdom

If we are unable to confirm or have reasonable doubts concerning the identity of the person making a request to exercise the rights above, we will require additional proof of identity (e.g. a copy of your driving licence or passport and a recent utility or credit card bill) and/or evidence of the requester’s authority to exercise these rights

We will ask for information on the right you wish to exercise and the information to which your request relates.

If you make a request, we will respond to you without undue delay and in any event within one month of your request.

Other matters

Encryption of data sent between us

We use Secure Sockets Layer (SSL) certificates to verify our identity to your browser and to encrypt any data you give us.

Whenever information is transferred between us, you can check that it is done so using SSL by looking for a closed padlock symbol or other trust mark in your browser’s URL bar or toolbar.

How you can complain

We hope that we can resolve any query or concern you may raise about our use of your information. If you do have a complaint, we hope that you will contact us first so that we can help resolve any issues you have. When we receive a complaint, we record all the information you have given to us.

We use that information to resolve your complaint.

If your complaint reasonably requires us to contact some other person, we may decide to give to that other person some of the information contained in your complaint. We do this as infrequently as possible, but it is a matter for our sole discretion as to whether we do give information, and if we do, what that information is.

We may also compile statistics showing information obtained from this source to assess the level of service we provide, but not in a way that could identify you or any other person.

However, if you are not happy with how we have processed your personal information, handled your privacy rights or responded to a privacy related complaint, you can raise a concern with the ICO at https://ico.org.uk/make-a-complaint/ or by telephoning +44 (0)303 123 1113.

Retention period for personal data

Except as otherwise mentioned in this privacy notice, we keep your personal information only for as long as required by us:

• to provide you with the services you have requested;
• to comply with other law, including for the period demanded by our tax authorities;
• to support a claim or defence in court.

Keeping your Personal Data Safe

We will take all steps necessary to ensure that your personal information is treated securely and in accordance with this privacy notice and UK data protection legislation. We employ best practice technical and organisational security protocols and procedures to ensure the protection of your personal information and to prevent unauthorised access to it.

Compliance with the law

Our privacy notice has been compiled to comply with the law of every country or legal jurisdiction in which we aim to do business. If you think it fails to satisfy the law of your jurisdiction, we should like to hear from you.

However, ultimately it is your choice as to whether you wish to use our website.

Review of this privacy notice

Changes may be necessary to this notice to reflect legal or data processing developments. If we change the notice, we will update them on our website so that you can review the changes. If at any stage there is a need for your personal information to be transferred or becomes subject to a different privacy notice we will make all reasonable attempts to notify you.

Changes may be necessary to this privacy notice from time to time to reflect contractual, legal or data processing developments. If we change this privacy notice, we will update it on our website.

The terms that apply to you are those posted here on our website on the day you use our website. We advise you to print a copy for your records.

If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact our DPO at dpo@healthhero.com

This Privacy Notice was last updated 05th May 2023.